We recognize that
your relationship with us is based on trust
and that you expect us to act responsibly
and in your best interests. Because your
personal is your private information, we
hold ourselves to the highest standards
in its safekeeping and use.

This means, most importantly,
that we do not sell client information—whether
it is your personal information or the fact
that you are a client—to anyone.

Instead, your information
is used by us primarily to complete transactions
that you request or to make you aware of
other services that we offer.

The
information we collect about you

You provide personal information
when you complete a Form. (If you enter
information in an online application, we
may store the information even if you don’t
complete or submit the application.)

Personal information collected
from any source may include your:

Name and address

email address

Phone information

Military rank

How
we handle your personal information

We do not
sell information about current or former
clients or their accounts to third parties.
Nor do we share such information, except
when needed to complete transactions at
your request or to make you aware of related
financial products and services that we
offer. Here are the details:

In order to complete certain
transactions or account changes that you
direct, it may be necessary to provide identifying
information to companies, individuals, or
groups that are not affiliated with us.

In certain instances,
we may contract with nonaffiliated companies
to perform services for us. Where necessary,
we will disclose information we have about
you to these third parties. In all such
cases, we provide the third party with only
the information necessary to carry out its
assigned responsibilities and only for that
purpose. And, we require these third parties
to treat your private information with the
same high degree of confidentiality that
we do.

Finally, we will release
information about you if you direct us to
do so, if we are compelled by law to do
so, or in other legally limited circumstances
(for example, to protect your account from
fraud).

How
we protect privacy online

Our concern for the privacy
of our shareholders naturally extends to
those who use our website.

Our website uses some of
the most secure forms of online communication
available, including data encryption with
names and passwords. These technologies
provide a high level of security and privacy
when you access your account information,
initiate online transactions, or send secure
messages.

How we safeguard your personal
information

We restrict access to
information about you to our employees who
need to know the information to provide
products or services to you. We maintain
strict physical, electronic, and procedural
safeguards to protect your personal information.

We'll
keep you informed

As required by federal
law, we'll notify you of our Privacy Policy
annually. We reserve the right to modify
this policy at any time, but rest assured
that if we do make changes, we'll tell you
promptly.